By David Wojick
I submitted the comments presented below on the draft Wyoming State Wildlife Action Plan (SWAP), pointing out several serious errors in their treatment of golden eagles. They do not give the severely threatened eagles anything like the priority that is needed for their protection, especially from being killed by wind turbines.
The comments are in the jargon of the SWAP, so here is a brief introduction. The SWAP homepage is here.
The SWAP is a federal report required for federal funding that is done every ten years. It identifies 308 “Species of Greatest Conservation Need” which are grouped by priority based on a complex ranking system. For each species it also gives a summary of helpful voluntary protective actions that might be taken as well as challenges. Despite the title, it is in no sense a plan, more of a hope list.
Regarding the jargon, NSS is the Native Species Status, which is the basic ranking. Ba and Bb are degrees of risk. In Bb, the population is declining, but the factors causing that decline are not increasing, while in Ba, they are increasing. There are two levels of priority — Tier I is high, and Tier II is lower.
Here are the comments regarding errors in the treatment of golden eagles:
“The Wyoming State Wildlife Action Plan (SWAP) has three primary components — (1) various rankings plus (2) challenges and (3) suggested volunteer actions. Our concern is the golden eagle which is incorrectly characterized in several ways, as briefly explained below.
First, in Table 2 the status should be Ba and NSS2 not Bb and NSS3. The major limiting factor of wind turbines killing eagles is severe and will continue to increase rapidly given present plans. Bb and NSS3 are for cases where the limiting factors are not growing and this is incorrect for the golden eagle.
Second, the priority should be Tier I not Tier II because the golden eagle is on the verge of ESA threatened status and conservation is clearly feasible. A stated goal of then SWAP is “reducing the need for future listings under the Endangered Species Act.” The already modest golden eagle population has reportedly dropped by 30% in the last two decades as the wind turbines have proliferated. The eagle is clearly threatened and preventing further decrease should be a very high priority, not Tier II.
See my prior article for more details.
Third, the recommended volunteer actions fail to include the obvious action of reducing the number of new wind turbines erected in Wyoming. Most of the developers have numerous projects outside of Wyoming and they could easily voluntarily forego building here, in order to save the eagles. This volunteer action should be added to the list.
Fourth, the recommendation that roadkill be collected in order to reduce vehicular collision may be a bad plan. The most recent FWS estimate of golden eagle death rates places starvation at the top of the list, far above collisions. Eagles are being struck because they are feeding on the roadkill. It is entirely possible that collecting roadkill would cause more eagle deaths from starvation than it prevents from collision. This volunteer action should be removed from the list until the issue is settled scientifically.
Fifth, the challenges say there is both a lack of information and a lack of funding for protecting the golden eagle. The eagle and these sad lacks should be at least mentioned, or better to be discussed, in Chapter 3 as the golden eagle is clearly a species of great conservation need.
In summary the golden eagle should have a much high priority than the present draft provides. I will be happy to provide additional information on this issue.
Respectfully submitted,
David Wojick, Ph.D.
CFACT”
End of Comments
Given the widespread and growing concern over Wyoming golden eagles being killed in increasing numbers by wind turbines, it is both astounding and disturbing that the SWAP gives them such a low priority. See for example this.
The draft SWAP is fundamentally wrong and must be corrected. Wyoming must act to protect the golden eagles.